Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Fair hearing in budgetary support claims requires the claimant to receive an opportunity to explain discrepancies between an input tax credit declaration and a Chartered Accountant certificate submitted at the respondents' direction. Where the declaration contains an asserted error, the officer must call for an explanation and consider supporting material before concluding the claim on merits. A claim cannot be finally determined merely by relying on the discrepant declaration without this opportunity. The challenged order was set aside to that extent, with directions to permit supporting documents and reconsider the claim after a reasonable hearing.
Fair hearing in budgetary support claims requires the claimant to receive an opportunity to explain discrepancies between an input tax credit declaration and a Chartered Accountant certificate submitted at the respondents' direction. Where the declaration contains an asserted error, the officer must call for an explanation and consider supporting material before concluding the claim on merits. A claim cannot be finally determined merely by relying on the discrepant declaration without this opportunity. The challenged order was set aside to that extent, with directions to permit supporting documents and reconsider the claim after a reasonable hearing.
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